Jurisdictional Defects and Denial of Hearing

This case highlights the critical importance of procedural safeguards in tax assessments. 

The Tribunal found that the assessee was not granted a meaningful opportunity of hearing and that key jurisdictional issues, particularly regarding notice under Section 143(2), were not examined. 

Rather than deciding on merits, the ITAT remanded the matter to the Assessing Officer for fresh adjudication. The decision reinforces that even substantive additions cannot survive if foundational procedural requirements are compromised.